Rene Julian McKenzie v. State of Minnesota

Summary

The Minnesota Supreme Court affirmed the denial of Rene Julian McKenzie’s petition for postconviction relief based on alleged recantation of trial testimony. The court held that McKenzie failed to prove substantial state interference with his witnesses’ decisions whether to testify, egregious prosecutorial misconduct warranting use immunity, or sufficient evidence under the Larrison test to justify a new trial.

Holdings

1. McKenzie failed to prove that the State substantially interfered with his witnesses' decisions about whether to testify; therefore, his Fourteenth Amendment due-process claim failed.
2. The postconviction court properly refused to grant use immunity because the statute authorizes immunity only upon a written prosecutorial request, and the State's conduct did not constitute egregious prosecutorial misconduct.
3. The postconviction court did not abuse its discretion in denying a new trial because McKenzie's third-party hearsay affidavit, standing alone and in light of the affiant's history of witness bribery and intimidation, did not provide sufficient indicia of trustworthiness to satisfy the first Larrison prong.

Questions Presented

1. Whether the State substantially interfered with McKenzie's witnesses' decisions about whether to testify at the postconviction evidentiary hearing, violating due process.
2. Whether the postconviction court erred by refusing to grant statutory use immunity to McKenzie's witnesses.
3. Whether the postconviction court abused its discretion by denying a new trial under the Larrison test based on alleged recantation evidence.

Disposition

affirmed